It also includes the DPIA, which in itself can be an expensive process. There was a lot of concern/press in Ireland pre-release about the privacy implications of the app. It's hot on the heels of a "mandatory but not compulsory" national ID card fiasco that was determined to be unlawful by the privacy regulator last year: https://www.thejournal.ie/psc-no-legal-basis-4766822-Aug2019...